LOCATION: United States Department of Health, Education, and Welfare: Social Security Division
DOCKET NO.: 74-204
DECIDED BY: Burger Court (1975-1981)
LOWER COURT: United States Court of Appeals for the Fourth Circuit
CITATION: 424 US 319 (1976)
ARGUED: Oct 06, 1975
DECIDED: Feb 24, 1976
Donald E. Earls - Argued the cause for the respondent
Robert H. Bork - Argued the cause for the petitioner
Facts of the case
George Eldridge, who had originally been deemed disabled due to chronic anxiety and back strain, was informed by letter that his disability status was ending and that his benefits would be terminated. Social Security Administration procedures provided for ample notification and an evidentiary hearing before a final determination was made, but Eldridge's benefits were cut off until that hearing could take place. Eldridge challenged the termination of his benefits without such a hearing.
Did the lack of an evidentiary hearing prior to the termination of disability benefits violate the Due Process Clause of the Fifth Amendment?
Media for Mathews v. EldridgeAudio Transcription for Oral Argument - October 06, 1975 in Mathews v. Eldridge
Audio Transcription for Opinion Announcement - February 24, 1976 in Mathews v. Eldridge
Warren E. Burger:
The judgment and opinion of the Court in 74-204, Matthews against Eldridge will be announced by Mr. Justice Powell.
Lewis F. Powell, Jr.:
This case is here on certiorari from the Court of Appeals for the Fourth Circuit.
It presents a question of what process is due when disability benefits are terminated.
Under the Social Security Act, a worker, receiving such benefits, has a burden of showing continuous disability.
When disability is put in issue, as it was with respect to respondent, regulations of the secretary of HEW prescribed an elaborate administrative review procedure, but this procedure does not include an oral evidentiary hearing prior to termination of benefits.
Respondent, in this case, challenged the validity of the procedure by suit in the Federal District Court.
That court, relying on this Court’s decision in Goldberg against Kelly, held that such a hearing was constitutionally required.
The Court of Appeals affirmed.
The decision whether to discontinue disability benefits normally turns upon documented medical evidence.
The issue of disability is a focused and limited one.
Prior to termination of benefits, the claimant is given access to government trials and to the reasons for the tentative decision to discontinue.
The claimant also is afforded an opportunity to submit additional evidence and arguments.
Following discontinuance of benefits, there is a right to an oral evidentiary hearing and ultimately to judicial review before the denial becomes final.
In view of the nature of the inquiry and a carefully structured system for administrative review, we find no deprivation of procedural due process.
Accordingly, we reverse the judgment of the Court of Appeals.
Mr. Justice Brennan has filed a dissenting opinion in which Mr. Justice Marshall has joined.
Mr. Justice Stevens took no part in the consideration or decision of the case.